Policy GNLP5005

Water Resources East Anglia is identified as an area of serious water stress. We strongly recommend that you require any new residential developments (not only for this consultation) are constructed to meet the optional higher water efficiency standard of 110 litres/person/day, as per Requirement G2 in Part G of the Building Regulations 2010.
GNLP5005 & GNLP5023
Foul Drainage Capacity
There is limited capacity at Wymondham Water Recycling Centre. The development is however small, but we would recommend that the constraints analysis is updated from green to amber for utilities capacity for this site.
Flood Risk/Permitting
This allocation borders the River Bays which is designated as a main river. Please note that a Flood Risk Activity Permit will be required for any development within 8m of this river. There are also Environment Agency maintained assets bordering this river (high ground) and this will most likely be taken into account in any permit application. We would require a strip of land to be left close to the river to allow access and avoid compromising the defences.
Contamination
In relation to contamination, this site resides in Source Protection Zone 3 (further information on SPZs can be found here Groundwater source protection zones (SPZs) - GOV.UK (www.gov.uk)) and is also on a principal aquifer. The site also overlies a historic landfill (Stayground Lane).
This would therefore trigger a consultation with us at the planning application stage. We would expect to see contaminated land assessments submitted as part of the application.
We have provided 2 consultation responses to planning applications on this site (under reference AE/2004/014191/06 and AE/2021/126063/01). The latter was South Norfolk DC application which can be found on their website under reference 2021/0607. You will see a desk study has already been produced. We would recommend taking a look at the outputs of this alongside our 2021 response.
In terms of Environment Agency comments in relation to contaminated land, we provide comments when sites have a ‘previously contaminative use’ as defined by the DoE Industry Profiles. A full list can be found here DoE Industry Profiles (claire.co.uk). We consider Waste disposal/treatment sites to be High Polluting Potential Previous Uses. I note that the site is also on a historic landfill sites and the Wymondham site resides within source protection zone 3. We would therefore expect to see contaminated land risk assessments submitted should the sites be brought forward. We are pleased to see that this is referenced as part of the site assessments for these sites. Any application should provide proportionate but sufficient site investigation information (a risk assessment) prepared by a competent person to determine the existence or otherwise of contamination, its nature and extent, the risks it may pose and to whom/what (the ‘receptors’) so that these risks can be assessed and satisfactorily reduced to an acceptable level. The National Quality Mark Scheme (NQMS) accredits competent persons with regard to assessing and reporting land contamination issues.
As with nearly all sites affected by contamination, most land contamination issues are surmountable with sufficient assessment and/or remediation (and as such, costs) if required. On this basis we would not rule out any development categorically on land contamination grounds at this stage. Whether or not it is economically viable however would be based on any risk assessments and cost benefit determination by any such developer.
Our main interest is when there is the breaking of ground. If the application is for the siting of caravans on this land it is likely to be of less concern to us. We would likely request that there should not be any piling or if necessary that a piling risk assessment is undertaken as piling can mobilise contaminants. We are also sharing the below SuDS informative which contains some useful guidance for these sites.
Advice to LPA on Sustainable Drainage Systems (SuDS) informative
1. Infiltration sustainable drainage systems (SuDS) such as soakaways, unsealed porous pavement systems or infiltration basins shall only be used where it can be demonstrated that they will not pose a risk to the water environment.
2. Infiltration SuDS have the potential to provide mobilise pollutants and must not be constructed in contaminated ground. They would only be acceptable if a site investigation showed the presence of no significant contamination.
3. Only clean water from roofs can be directly discharged to any soakaway or watercourse. Systems for the discharge of surface water from associated hard-standing, roads and impermeable vehicle parking areas shall incorporate appropriate pollution prevention measures and a suitable number of SuDS treatment train components appropriate to the environmental sensitivity of the receiving waters.
4. The maximum acceptable depth for infiltration SuDS is 2.0 m below ground level, with a minimum of 1.2 m clearance between the base of infiltration SuDS and peak seasonal groundwater levels.
5. Deep bore and other deep soakaway systems are not appropriate in areas where groundwater constitutes a significant resource (that is where aquifer yield may support or already supports abstraction).
6. SuDS should be constructed in line with good practice and guidance documents which include the SuDS Manual (CIRIA C753, 2015), Guidance on the Construction of SuDS C768 and the Susdrain website. For further information on our requirements with regard to SuDS see our Groundwater protection position statements (2018), in particular Position Statements G1 and G9 – G13 available at: https://www.gov.uk/government/publications/groundwater-protection-position-statements
We recommend that developers should
1) Refer to our ‘Groundwater Protection’ website;
2) Refer to our CL:AIRE Water and Land Library (WALL) and the CLR11 risk management framework provided in https://www.gov.uk/guidance/land-contamination-how-to-manage-the-risks when dealing with land affected by contamination, and also includes the Guiding Principles for Land Contamination for the type of information that we require in order to assess risks to controlled waters from the site. The Local Authority can advise on risk to other receptors, for example human health;
3) Refer to our Land Contamination Technical Guidance;
4) Refer to ‘Position Statement on the Definition of Waste: Development Industry Code of Practice’;
5) Refer to British Standards BS 5930:1999 A2:2010 Code of practice for site investigations and BS10175:2011 A1: 2013 Investigation of potentially contaminated sites – code of practice
6) Refer to our ‘Piling and Penetrative Ground Improvement Methods on Land Affected by Contamination’ National Groundwater & Contaminated Land Centre Project NC/99/73. The selected method, including environmental mitigation measures, should be presented in a ‘Foundation Works Risk Assessment Report’, guidance on producing this can be found in Table 3 of ‘Piling Into Contaminated Sites’;
7) Refer to our ‘Good Practice for Decommissioning Boreholes and Wells’.
8) Refer to our ‘Dewatering building sites and other excavations: environmental permits’ guidance when temporary dewatering is proposed
Waste Management Licences
Waste Management Licence 70519 is located on site. We would expect this to be surrendered as appropriate should waste operations cease.
GNLP5014, GNLP5019, GNLP5020, GNLP5021 & GNLP5024
Foul Drainage
This site does not appear to have access to mains drainage. Therefore, private means of foul drainage may be necessary. We would therefore suggest that the constraints analysis for ‘utlilities infrastructure’ is updated from green to amber.
Government guidance contained within the National Planning Practice Guidance (Water supply, wastewater and water quality – considerations for planning applications, paragraph 020) sets out a hierarchy of drainage options that must be considered and discounted in the following order which must be followed at application stage:
1. Connection to the public sewer
2. Package sewage treatment plant (adopted in due course by the sewerage company or owned and operated under a new appointment or variation)
3. Septic Tank
Foul drainage should be connected to the main sewer. Where this is not possible, under the Environmental Permitting Regulations 2010 any discharge of sewage or trade effluent made to either surface water or groundwater will need to be registered as an exempt discharge activity or hold a permit issued by the Environment Agency, addition to planning permission. This applies to any discharge to inland freshwaters, coastal waters or relevant territorial waters.
Planning and permitting are separate regimes so we would highlight that should this site be brought forward that there is no guarantee of the granting of an Environmental Permit. We would therefore recommend applicants contact us as soon as possible regarding the application for the relevant permits. Upon receipt of a correctly filled in application form we will carry out an assessment.
Domestic effluent discharged from a treatment plant/septic tank at 2 cubic metres or less to ground or 5 cubic metres or less to surface water in any 24 hour period must comply with General Binding Rules provided that no public foul sewer is available to serve the development and that the site is not within a Groundwater Source Protection Zone.
A soakaway used to serve a non-mains drainage system must be sited no less than 10 metres from the nearest watercourse, not less than 10 metres from any other foul soakaway and not less than 50 metres from the nearest potable water supply, spring or borehole.
Where the proposed development involves the connection of foul drainage to an existing non-mains drainage system, the applicant should ensure that it is in a good state of repair, regularly de-sludged and of sufficient capacity to deal with any potential increase in flow and loading which may occur as a result of the development.
Where the existing non-mains drainage system is covered by a permit to discharge then an application to vary the permit will need to be made to reflect the increase in volume being discharged. It can take up to 13 weeks before we decide whether to vary a permit.
We trust this advice is useful.

My comments for GNLP5023 also apply to this site.

Wymondham Town Council has considered this consultation and at this stage
wishes to only make the following comments and to confirm that no
pre-determination has been made .. We reserve the right to formally respond to any
further consultation (s) or planning application (s).
Prospective sites 5005 and 5023 are adjacent to each other and these comments
refer to them both and to their locations.
This area of Wymondham is of a rural nature following its previous commercial part
use for mineral extraction and latterly partly as a waste disposal site operated by
Norfolk County Council. The relocation of the waste site (5005) and acquisition of
the adjacent site (5023) could afford the opportunity to restore these areas as part
of the already existing Bays River County Wildlife site. The area is also popular
with walkers and ramblers from the Town centre into open countryside and the
reduction in waste site traffic would enhance their experience and would improve
their safety.
Concerns have been raised that any alteration to the existing road to accommodate
a Gypsy & Travellers site would have to be carefully considered so as not to
damage its rural character.
To summarise the Town Council has made no decision on these proposals, other
than to highlight that consideration should be taken into account when suitability
assessments are made of the effect on the existing rural road network, and the
potential to enhance the nearby wildlife sites and trails that are enjoyed by a
considerable number of ramblers and walkers.

I object to any proposed Travellers Site in Strayground Lane, off London Road, Wymondham.

The site is entirely unsuitable for Travellers, being remote from the facilities of the Town and with restricted access. However, Strayground Lane is eminently suitable as a route to open countryside beyond and is part of the "Green Ribbons" strategy identified in the Neighbourhood Plan.

The site has already been impacted by the aggressive clearing which is enclosed by industrial fencing. This is entirely detrimental to the character of the Bays River County Wildlife Site. The proposed closing of the Waste Site gives ample opportunity to reinstate the area as part of the County Wildlife Site. It is time to pay other than lip service to the prospect of the site becoming a haven for wildlife, thus creating a superb Reserve for the benefit of future generations. This is not suitable for a Travellers Site.

The nearby Travellers site in Suton is now established; the later one in London Road is subject to an Eviction Order which has been delayed. Any concreting or buildings on the Strayground Lane site would render it completely inhospitable to wildlife, flora and fauna.

Walkers have had to/are currently negotiating the uneven banks along Strayground Lane in order to run the gauntlet of passing cars, vans and lorries to the Waste Tip - it is eminently time to eradicate the need for excessive vehicles along this narrow and unique by-way.

Please eliminate the Strayground Lane proposal as a Travellers site from the GNLP.

1. Anglian Water
1.1. Anglian Water is the water and water recycling provider for over 6 million customers in the east of England. Our operational area spans between the Humber and Thames estuaries and includes around a fifth of the English coastline. The region is the driest in the UK and the lowest lying, with a quarter of our area below sea level. This makes it particularly vulnerable to the impacts of climate change including heightened risks of both drought and flooding, including inundation by the sea.
1.2. Anglian Water has amended its Articles of Association to legally enshrine public interest within the constitutional make up of our business – this is our pledge to deliver wider benefits to society, above and beyond the provision of clean, fresh drinking water and effective treatment of used water. Our Purpose is to bring environmental and social prosperity to the region we serve through our commitment to Love Every Drop.
2. Anglian Water and Local Plans 2.1. Anglian Water is is the statutory water and sewerage undertaker for the Greater Norwich Local Plan (GNLP) area and a statutory consultee under The Town and Country Planning (Local Planning) (England) Regulations 2012. Anglian Water wants to proactively engage with the local plan process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. As a purpose-led company, we are committed to seeking positive environmental and social outcomes for our region.
3. Commentary on the GNLP Gypsy & Traveller Sites Focused Consultation
3.1. Anglian Water has contributed to the utilities assessment of the proposed Gypsy and Traveller sites regarding connections to our water supply and water recycling networks and any identified encroachment issues on our assets/network.
3.2. We recognise the wider policy considerations that inform the selection of proposed sites within this consultation. The ability to connect to our networks where sites are adjacent to larger settlements that are serviced by a water recycling centre (WRC) means there are more sustainable and resilient options to treating wastewater arising from Gypsy and Traveller sites. Many of the sites are in rural locations or not closely related to our WRC catchments and therefore are likely to be reliant on non-mains sewerage solutions such as private package treatment plans. A joint advice note by Anglian Water and the Environment Agency in relation to non-mains sewerage options can be found on our website1.
1 https://www.anglianwater.co.uk/contentassets/ff314e5a2ec1452387d7aa04f6519c33/2020-11-10-aw-ea-non-mains-sewerage-advice-note---final.pdf
09.03.2023
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POLICY GNLP5004 LAND OFF BUXTON ROAD, EASTGATE, CAWSTON
3.3. Anglian Water notes the site is located close to existing development within the settlement, and therefore it is within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5005 LAND AT STRAYGROUND LANE WYMONDHAM RECYCLING CENTRE, WYMONDHAM
3.4. As referenced as part of the initial assessment, this site is within reasonable proximity to connect to our water supply network, but it is located outside the Wymondham water recycling catchment.
POLICY GNLP5009 LAND OFF HOCKERING LANE, BAWBURGH
3.5. Anglian Water notes the site is located close to existing development within the settlement, and within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5014 A47 NORTH BURLINGHAM JUNCTION
3.6. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.7. The A47 road improvement scheme will require the diversion of our assets at this location, and this should be a consideration for future connections.
POLICY GNLP5019 WOODLAND STABLE, SHORTTHORN ROAD, STRATTON STRAWLESS
3.8. The site is located within reasonable proximity to connect to our water supply network, and is adjacent to the Aylsham water recycling catchment, although this part of the network operates as a vacuum sewer system which can take up to 24 months for a connection due to the requirements to assess the capacity of the network. We would suggest that any policy should include a requirement for early engagement with Anglian Water regarding connection to our water recycling network.
POLICY GNLP5020 ROMANY MEADOW, THE TURNPIKE, CARLETON RODE
3.9. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5021 LAND OFF HOLT ROAD, HORSFORD
3.10. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.11. There is a mains water pipe to the northern boundary of the site. We will require sufficient stand-off distances around the water main or diversion at the developers' cost and to the satisfaction of Anglian Water. Further information on the location of our assets can be obtained via utilities.digdat.co.uk
09.03.2023
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POLICY GNLP5022 LAND OFF REEPHAM ROAD, THE OAKS, FOULSHAM
3.12. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5023 LAND OFF STRAYGROUND LANE, WYMONDHAM
3.13. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5024 UPGATE STREET, CARLETON RODE
3.14. This site does not appear to be in close proximity to a water supply connection or our water recycling network. As the neighbouring site is occupied and was granted planning permission in 2010, there is an assumption that a water supply is available and sewerage treatment is confirmed as a package treatment plant through the documents submitted with the planning application.
Reasonable Alternative
POLICY GNLP5013 KETTERINGHAM DEPOT LAND WEST OF STATION LANE, KETTERINGHAM
3.15. As a reasonable alternative site, Anglian Water notes that the site is located within reasonable proximity to connect to our water supply network, but it is not within reasonable distance of our water recycling network catchments.
Unreasonable Alternatives
VCHAP SITE 1 AND SITE 2, MIDDLE ROAD, DENTON
3.16. Anglian Water notes the constraints identified regarding these sites and reasons why they have not been brought forward. In terms of access to our water supply and water recycling networks we can state that these sites are located within reasonable proximity to connect to our water supply network, but due to the rural location of these sites, they are not within reasonable distance to connect to our water recycling network catchments.
4. Conclusion
4.1. Anglian Water has assessed the potential to access our water supply and water recycling networks for the proposed Gypsy and Traveller Sites and identified where there are policy requirements regarding connections to our network or to ensure sufficient measures are in place to protect our assets within or adjacent to the proposed sites.

SUMMARY
Whilst we consider many aspects of the plan to be sound, we have identified issues
with some of the policies and site allocations which do compromise the overall
soundness of the plan.
Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they
have not been positively prepared, are not justified, effective, or consistent with
national policy. We have identified below some of the key areas where we find the
Plan unsound and what measures are needed to make the Plan sound. In summary
we highlight the following issues
1. Recommended changes to policy wording
We are pleased to see the site assessments and sustainability appraisal for the
allocations. Although these are not full heritage impact assessments, these
assessments do make some helpful recommendations for the sites.
However, these recommendations are not always reflected in the policy.
As currently drafted, there is sometimes either a lack of criteria or insufficient
detail within the site-specific policies for the conservation and enhancement of
the historic environment. The NPPF (para 16d) makes it clear that Plans should
contain policies that are clearly written and unambiguous, so it is evident how a
decision maker should react development proposals. Further advice on the content of
policies is given in the PPG at Paragraph: 002 Reference ID: 61-002-20190315
Revision date: 15 03 2019. It states that, ‘Where sites are proposed for allocation,
sufficient detail should be given to provide clarity to developers, local communities
and other interested parties about the nature and scale of development’.
We have therefore suggested a number of relatively minor changes to the policies to
incorporate these recommendations and address some of our concerns.
2. Heritage Impact Assessment of Bawburgh Site
The Bawburgh Site is perhaps most sensitive in heritage terms. There are several
designated heritage assets nearby including the Conservation Area, listed buildings
and scheduled monuments. Indeed, the Site Assessment states that a Heritage
Impact Assessment (HIA) may be required. We concur with this.
Paragraph 31 and 192 of the NPPF requires a proportionate evidence base for Plans
and we consider that an HIA for this site would help to ensure a robust evidence
base for the Local Plan.
Therefore, we recommend that a proportionate Heritage Impact Assessment is
undertaken now to inform the suitability of the site per se, assess the impact, identify
any mitigation and enhancement required and inform any changes to policy wording.
We would remind you that paragraph 32 of the NPPF makes it clear that significant
adverse impacts should be avoided wherever possible and alternative options
pursued. Only where these impacts are unavoidable should suitable mitigation
measures be proposed. Further detail is given in the attached table.
Where a potential impact is identified, wording should be included in the policy and
supporting text to this effect. We suggest the inclusion of additional bullet point in the
site allocation. Ideally, the bullet point should mention the specific asset(s), the policy
requirement (see wording in appendix) and any potential mitigation required.
Closing comments
We have suggested a series of other changes to the Plan. Many of these changes
suggested do not go to the heart of the Plan’s soundness, but instead are intended to
improve upon it. We believe that these comments can be addressed by changes to
wording in the plan.
In preparation of the local plan, we encourage you to draw on the knowledge of local
conservation officers, the county archaeologist and local heritage groups.
Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU
Telephone 01223 58 2749 HistoricEngland.org.uk
Please note that Historic England operates an access to information policy.
Correspondence or information which you send us may therefore become publicly available.
Please note that absence of a comment on a policy, allocation or document in this
letter does not mean that Historic England is content that the policy, allocation or
document is devoid of historic environment issues. We should like to stress that this
response is based on the information provided by the Council in its consultation. To
avoid any doubt, this does not affect our obligation to provide further advice and,
potentially, object to specific proposals, which may subsequently arise as a result of
this plan, where we consider that these would have an adverse effect upon the
historic environment.


GNLP5004
Land off Buxton Road, Eastgate, Cawston
The policy states that an archaeological assessment will be required prior to development which is broadly welcomed. The SA recommends that the policy should make it clear whether these should be desk based of field studies. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA also recommends that the landscaping should be species appropriate to the local area.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Amend policy to state that ‘landscaping should be species appropriate to the local area.’

GNLP5005
Strayground Lane, Wymondham Recycling Centre
No comments

GNLP5009 Hockering Lane, Bawburgh

Whilst there are no designated heritage assets within the site, the Bawburgh Conservation Area lies to the west of the site but is separated by a block of development. There are listed buildings and scheduled monuments to the north west of the site across the valley. The development has the potential to impact the significance of these heritage assets via a change in their settings.
The Site assessment suggests the preparation of a Heritage Impact Assessment. The Sustainability Appraisal identifies negative impact.
Given this is one of the more sensitive sites in heritage terms, an HIA should be prepared now to inform the suitability of the site per se and the policy wording.
The policy states that an archaeological assessment will be required prior to development. As with the Cawston site it would helpful for the policy to state if the assessment should be desk based or field based. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA recommends that the policy should protect or where possible enhance the trees and hedgerow surrounding the site, which would be likely to help conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened. This should be included in the policy.
We recommend an HIA is prepared now prior to inform the suitability of the site and policy wording.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Add criterion to read ‘Protect and enhance the trees and hedgerows surrounding the site to conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened’.

GNLP5014
A47 North Burlingham Junction
We welcome bullet point 3 in relation to landscaping to protect views of non-designated heritage assets nearby.

GNLP5019 Woodland Stable, Shortthorn Road, Stratton Strawless
No comments

GNLP5020 Romany Meadow, The Turnpike, Carleton Rode
Whilst there are no designated heritage assets within the site, there are several grade II listed buildings nearby including The Ashes to the east and a cluster of grade II properties to the northwest. However, the site is quite well contained and intervening landscaping should limit the impact on the historic environment.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5021 The Old Produce Shop, Holt Road, Horsford
No comments

GNLP5022 The Oaks, Foulsham
This is an extension of an existing site. Whilst there are no designated heritage assets within the site, the grade II* church of St Andrew lies to the south east of the site. There are three grade II listed buildings close by including Manor Farm House to the west, Old Hall to the East and Old Hall Farmhouse to the north east of the site. However, the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage assets would be minimal.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5023 Strayground Lane, Wymondham
The SA states that the policy could be further improved by detailed requirements to consider landscaping measures to reduce potential for adverse effects on the surrounding landscape character
Add policy criterion to read
‘Landscaping measures to reduce potential for adverse effects on the surrounding landscape character’

GNLP5024 Upgate Street, Carleton Rode
Whilst there are no designated heritage assets within the site, there are two grade II listed buildings to the north of the site and the New Buckenham Conservation Area to the west of the site. The site assessment states that Bunns Bank Linear Earthwork, which elsewhere in its course is scheduled, is adjacent to the site and should be taken into consideration. This requirement should be included in the policy wording of the Plan. We suggest an additional bullet point to the policy criteria.
However, overall the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage would be minimal.
Amend policy wording to add bullet point to read:
‘Protect the adjacent Bunns Bank Linear Earthwork.‘

Reasonable Alternative Site Policy GNLP5013 Ketteringham Depot land west of Station Lane, Ketteringham
Whilst there are no designated heritage assets within the site boundary, there are two round barrows (scheduled monuments) to the south of the site and several grade II listed buildings nearby. However, these are all over 500 metres from the site. Given the distance and intervening vegetation, we consider there would be little impact on designated heritage.

Please note that there is Japanese knotweed on the edge of this site. It will need to be treated as a matter of urgency

I support GNLP5005 because it is a brownfield site and secluded by trees, this will minimise the impact on the local community and be pleasant surroundings for occupants.

Roll Forward GNLP, comments on Strayground Lane proposed Travellers Site
Sites GNLP 5005 and GNLP 5023
History.
Despite the recent past use of the land either side of the lane for mineral extraction and waste disposal, it still retains the character and charm of a rural thoroughfare. Indeed the classification as a “byway open to all traffic” identifies that past history. The recent clearing of the site beyond the waste facility (see attached photo file) and enclosure with a brutal industrial style fence has adversely impacted on that lane and is detrimental to the character of the Bays River Valley County Wildlife Site. In contrast the large former gravel working site adjacent to Pear Tree Cottage at the bend of the lane is being restored by the owners and will be planted up. (ref the plan submitted with Planning Application 2022/1628) The restoration of former industrial sites for wildlife and public enjoyment is common practice in all areas of the country, for example coal pits and mine workings.
Future use of the site.
Most people have sympathy with the plight of the Travellers seeking a home. However the question of whether this site is a suitable one is not really about this case in particular. Use has made use of the minerals – gravel and sand – extracted here and the excavations used for waste disposal. It is now time to return the land to nature as part of the Bays River County Wildlife Site. The Norfolk Wildlife Trust has been asked to consider making the area and possibly the River Tiffey, Toll’s Meadow and the Lizard into Claylands 2, a conservation Project designed to preserve and enhance wetland habitat. This would involve local people and volunteers and follow on from the first Claylands Project.
Strayground Lane is an important and popular route for walkers and cyclists. It gives access from the town centre via Toll’s Meadow and Cemetery Lane to the open countryside beyond. It is part of the Green Ribbons Strategy outlined in the Neighbourhood Plan which is soon to be approved.
Traffic Considerations
The route from the B1172 via Wharton’s Lane and Strayground Lane is very narrow and twisting, with poor visibility. Any volume of traffic using the lanes is in conflict with walkers and cyclists. The road is so narrow that pedestrians are forced to climb onto the verge so that vehicles can pass. Any improvements made to the road would risk losing the rural character and encroaching on the County Wildlife Site. The inadequacy of the access means that realistically further industrial use of sites along the Land would be ruled out.
Development of the proposed sites for up to twelve Travellers pitches is bound to create traffic movements of cars and Lorries. The distance from facilities such as schools, shops, and medical facilities means that the residents would tend to use their vehicles rather than walking. They will also be carrying on their businesses using Lorries as well. All this will bring vehicles into conflict with walkers and cyclists, thus continuing current problems. Any other development of the site would be accompanied by traffic conflict implications.
There is also the problem of poor visibility at the junction of Wharton’s Lane with the B1172. It seems difficult to see how this can be improved due to the bridge parapet over the adjacent Railway Line.

Supporting Documentary evidence.
When considering this proposal I would hope that the Inspectors would refer to the Appeal Decision 3246540 concerning the Travellers site on the B1172 London Road, Suton. I would refer them to the following comments because they seem relevant to the Strayground Lane sites:
“…I see no reason to dispute that the site is in open countryside and is away from local settlements.””…it was accepted that occupants of the site would be dependent on the car for access to local services. This is because of the realistic acceptance that culturally gipsies are most likely to drive but also because the surrounding network is not conducive to walking”
“…8 families with their dependants is a sizeable number of people without counting any visiting families traveling in the area. Within the context of the local settlement pattern the site amounts to a small village in its own right and with the numbers of people and its compact nature it would clearly dominate the locality and be contrary to DM 3.3 1(a)”
Impact on landscape and heritage assets
This section describes the impact on the locality, which in that case is “…pleasantly agricultural with fields bounded by hedges, trees and generally quiet rural lanes.”
Although the Strayground Lane site has a different character, that of a largely undisturbed wet land, intruded upon and degraded by industrial use. I would hope the Inspectors can give this the benefit of a similarly sympathetic landscape assessment.
Recent Publication.
I attach pages from a book recently published by local author Rosamunde Codling “Landscape a Common Place”, describing her thoughts when walking along Strayground Lane in the early days of the Covid lockdown. She sketches her feelings about a modest lane that forms an integral part of our understanding of our community. The book as a whole concerns the effect that our history has on our core feelings and enjoyment of our landscapes. There are only a few of the old lanes left in Wymondham and all are fragile, in danger of being damaged by development. They are much valued by the community and in particular by walkers note the outcry that resulted from trees being felled recently at Right-up Lane to facilitate housing development and a proposal to develop land at Lady’s Lane (221 1935).
Conclusion.
From the foregoing it must be apparent that objections to this proposal should not in the main be concerned with the use of the site by Travellers but with making sure that the site does not generate future traffic movement. That the peaceful tranquillity and sense of history of the lane is preserved and enhanced. That the site is restored to nature as part of the Bays River County Wildlife Site for general public enjoyment and that the importance of the lane as part of a primary walking route from the urban environment to open countryside is preserved and enhanced.
Ann Rostron and 14 other Members of the Greening Wymondham Committee Local environmental Group